Wash. Rev. Code » Title 4 · Chapter 4.16
Revised Code of Washington

Wash. Rev. Code § 4.16.020 (2026)

✓ current as of May 2026
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The period prescribed for the commencement of actions shall be as follows:
Within ten years:
(1) For actions for the recovery of real property, or for the recovery of the possession thereof; and no action shall be maintained for such recovery unless it appears that the plaintiff, his or her ancestor, predecessor or grantor was seized or possessed of the premises in question within ten years before the commencement of the action.
(2) For an action upon a judgment or decree of any court of the United States, or of any state or territory within the United States, or of any territory or possession of the United States outside the boundaries thereof, or of any extraterritorial court of the United States, unless the period is extended under RCW 6.17.020 or a similar provision in another jurisdiction.
(3) Of the eighteenth birthday of the youngest child named in the order for whom support is ordered for an action to collect past due child support that has accrued under an order entered after July 23, 1989, by any of the above-named courts or that has accrued under an administrative order as defined in RCW 74.20A.020(6), which is issued after July 23, 1989.
[ 2002 c 261 s 2; 1994 c 189 s 2; 1989 c 360 s 1; 1984 c 76 s 1; 1980 c 105 s 1; Code 1881 s 26; 1877 p 7 s 26; 1854 p 363 s 2; RRS s 156.]

Notes:

Application—1980 c 105: "This act shall apply to all judgments which have not expired before June 12, 1980." [ 1980 c 105 s 7.]
Adverse possession
limitation tolled when personal disability: RCW 7.28.090.
recovery of realty, limitation: RCW 7.28.050.
Notes of Decisions
Cited in 145 cases (15 in the last 5 years), 1952–2026 · leading case: Highline Sch. Dist. No. 401 v. Port of Seattle, 548 P.2d 1085 (Wash. 1976).
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Highline Sch. Dist. No. 401 v. Port of Seattle, 548 P.2d 1085 (Wash. 1976). · cites it 3× “The 10-year period in RCW 4.16.020, 4 the successor to Rem. Rev.”
Nickell v. Southview Homeowners Ass'n, 271 P.3d 973 (Wash. Ct. App. 2012). · cites it 3× “2d at 757 (citing RCW 4.16.020). 10 “A claimant can satisfy the open and notorious element by showing either (1) that the title owner had actual notice of the adverse use throughout the statutory period or (2) that the claimant used the land such that any reasonable person would…”
Gorman v. City of Woodinville, 283 P.3d 1082 (Wash. 2012). · cites it 2× “¶17 In this state the doctrine of adverse possession is primarily covered by three statutes of limitation: RCW 4.16.020, RCW 7.28.070, and RCW 7.28.”
Orion Corp. v. State, 747 P.2d 1062 (Wash. 1987). · cites it 2× “Orion's action, filed in 1982, comes within the federal 3-year limitation, as well as the 6-year and 10-year alternatives.”
Lilly v. Lynch, 945 P.2d 727 (Wash. Ct. App. 1997). · cites it 2× “2d at 857 ; RCW 4.16.020. Both parties agree that Lilly has demonstrated conditions (2), (3) and (4).”
Acord v. Pettit, 302 P.3d 1265 (Wash. Ct. App. 2013). · cites it 2× “2d 6 (1989); RCW 4.16.020. The Acords can also “tack” the possession of a predecessor in interest to establish the use required for adverse possession.”
Darlington Ofuasia Et Al., Appellants, v. Dana William Smurr Et Al., Respondents, 392 P.3d 1148 (Wash. Ct. App. 2017). “at 50 ; RCW 4.16.020(1). A claimant can satisfy the open and notorious element by showing either that the title owner had actual notice of the adverse use throughout the statutory period or that the claimant, or predecessor- *144 in-interest, used the land such that any…”
Roy v. Cunningham, 731 P.2d 526 (Wash. Ct. App. 1986). · cites it 2× “RCW 4.16.020; Chaplin , at 857. The hostility/claim of right element requires only that the claimant "treat the land as his own as against the world throughout the statutory period".”
State v. Morgan, 107 Wash. App. 153 (Wash. Ct. App. 2001). · cites it 4× “The Legislature added the extension provision to RCW 4.16.020 in 1994. Laws of 1994, ch. 189, § 2.”
Chaplin v. Sanders, 676 P.2d 431 (Wash. 1984). “RCW 4.16.020. Hostility, as defined by this court, "does not import enmity or ill-will, but rather imports that *858 the claimant is in possession as owner, in contradistinction to holding in recognition of or subordination to the true owner.”
Bradley v. Am. Smelting & Refining Co., 709 P.2d 782 (Wash. 1985). “We note that RCW 4.16.020(1) creates a right of adverse possession 10 years after initial possession.”
Lingvall v. Bartmess, 982 P.2d 690 (Wash. Ct. App. 1999). · cites it 2× “777 (1904), with RCW 4.16.020. If the essential factual findings are not in dispute, whether use is adverse or permissive is purely a question of law.”
Show all 145 citing cases →
— Wash. Rev. Code § 4.16.020(1) — 16 cases
Darlington Ofuasia Et Al., Appellants, v. Dana William Smurr Et Al., Respondents, 392 P.3d 1148 (Wash. Ct. App. 2017). “at 50 ; RCW 4.16.020(1). A claimant can satisfy the open and notorious element by showing either that the title owner had actual notice of the adverse use throughout the statutory period or that the claimant, or predecessor- *144 in-interest, used the land such that any…”
Bradley v. Am. Smelting & Refining Co., 709 P.2d 782 (Wash. 1985). “We note that RCW 4.16.020(1) creates a right of adverse possession 10 years after initial possession.”
In re Kelly, 170 Wash. App. 722 (Wash. Ct. App. 2012).
Nickell v. Southview Homeowners Ass'n, 271 P.3d 973 (Wash. Ct. App. 2012). “2d at 757 (citing RCW 4.16.020). 10 “A claimant can satisfy the open and notorious element by showing either (1) that the title owner had actual notice of the adverse use throughout the statutory period or (2) that the claimant used the land such that any reasonable person would…”
Teel v. Stading, 228 P.3d 1293 (Wash. Ct. App. 2010).
— Wash. Rev. Code § 4.16.020(2) — 17 cases
Bjurstrom v. Campbell, 618 P.2d 533 (Wash. Ct. App. 1980).
Stokes v. Polley, 145 Wash. 2d 341 (Wash. 2001).
Stokes v. Polley, 37 P.3d 1211 (Wash. 2001).
Tcap Corp. v. Gervin, 185 P.3d 589 (Wash. 2008).
TCAP Corp. v. Gervin, 163 Wash. 2d 645 (Wash. 2008).
— Wash. Rev. Code § 4.16.020(3) — 4 cases
In re the Marriage of Waters, 63 P.3d 137 (Wash. Ct. App. 2002).
In the Matter of the Marriage of: Shennen Goodyear-Blackburn & Shawn Blackburn (Wash. Ct. App. 2020).
In Re: Lori J. Jordan v. Stephen Earl Whitted (Wash. Ct. App. 2018).
Ronald C. Moates, V. Deidre D. Moates (Wash. Ct. App. 2021).
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